Last Updated: [August 26, 2022]
Your privacy is important to us at Naenu, Inc. (“Naenu,” “we,” “us,” or “our”), and we are committed to safeguarding, preserving, and respecting your privacy rights. This online privacy statement (the “Statement” or “Policy”) describes how we collect, use, disclose, and the security of the personal information we gather about you through our Website, [https://mementos.one], our application, or when we interact with you through otherwise (together, the “Services”).
For purposes of this Statement, personal information means data that classifies as personal information, personal data, personally identifiable information, or similar terms under applicable data privacy and security laws and regulations. It does not include data excluded or exempted from those laws and regulations, such as deidentified, anonymized, or aggregated data. Nothing in this Statement will constitute an admission or evidence that any particular data privacy or information security law or regulation applies to Naenu generally or in any specific context.
Our Services are used at times by third parties in connection with the services they provide. This Policy does not apply to how third parties may collect and process personal information, and you should consult their applicable privacy policies and terms.
You Consent to This Statement
You should read this Statement carefully. We recommend printing and retaining a copy for your future reference. By accessing, browsing, or otherwise using the Services, you confirm that you have read, understood, and agreed with this Statement. If you do not agree to this Statement, you may not use the Services.
This Statement applies regardless of how the Services are accessed and will cover any technologies or devices by which we make the Services available to you.
We may provide you with additional privacy notices and terms where we believe it is appropriate to do so. It is important that you read this Statement together with any other privacy notice or terms we may provide on specific occasions, so that you are fully aware of how and why we are using your data. This Statement supplements these other notices and is not intended to override them.
If you have any questions or concerns about our personal information policies or practices, you can contact us in the methods described in the “Contact Us” section below.
The Information We Collect
We collect the information you voluntarily provide directly to us, such as when you complete a form or submit information to us. We also collect information when you interact with the Services, for example, through our use of cookies.
Information You Provide
- Completing Forms Through Our Services. If you request to receive information or fill out any forms through our Services, we may ask you to provide information such as your name and email address.
- Purchasing Goods Through Our Services. If you purchase any goods we may ask you to provide information such as your name, email address, mailing address, phone number, and payment information.
- Social Media. If you interact with our Services through social media, we may collect information that you post. Please note that your comments and information will be visible to the public, so you should never share personal information that you would like to keep private.
- When You Contact Us. If you send us an email or otherwise contact us, we will collect your email address and any information that you provide in the email.
- Job Applications and Employment. If you apply for a job with or are employed or contracted by us, we will collect various pieces of information about you to administer the employment relationship, provide benefits, and ensure security. Such information will vary depending on your role, but it would likely include name, social security number, educational information, and financial account information.
Information That We Collect About You
We may collect information about you from third parties, such as athletic organizations or events. The nature of the information will change depending on the event, but it may include contact information, results, and awards given. If that information is received pursuant to a contract with that third party, our processing will be governed by that contract
Information We Collect as You Navigate Our Site
We automatically collect certain information as you use the Services, such as the following:
- Usage Information. We may collect information automatically through your use of the Services, such as which of the pages on the Services you access, the frequency of access, and how long you use our Services.
- Device Information. We may collect information about the device you are using, such as hardware model, operating system, application version number, browser, and IP addresses.
- Mobile Device Information. When you access our Services via a browser on your mobile device, we may also collect mobile network information, including telephone number, the unique device identifier assigned to that device, mobile carrier, operating system, and other device attributes.
- Location Information. We may collect information about your actual location which may be determined from GPS and other sensors that may reveal information on or nearby devices, Wi-Fi access points, and cell towers.
How Do We Use “Cookies” and Other Tracking Technologies?
We may send one or more Cookies to your computer or other device. We may also use other similar technologies such as tracking pixels, tags, or similar tools when you visit our Services.
Cookies are small files created by websites, including our Services, that reside on your computer’s hard drive and that store information about your use of a particular website. When you access our Services, we use Cookies and other tracking technologies to:
- Estimate our audience size and usage patterns;
- Store information about your preferences, allowing us to customize our Services according to your individual needs;
- Contact you to provide you with information or services that you request from us;
- Advertise new content, events, and services that relate to your interests;
- Provide you with more personalized content that is most relevant to your interest areas; and
- Recognize when you return to our Services.
You can manage your Cookies preference as described in the “Managing Your Cookies” section below.
What Types of Cookies Do We Use and Why?
The following chart lists the different types of Cookies that we and our service providers use on the Services, examples of who serves those Cookies and links to the privacy notices and opt-out information of those Cookie servers.
| Types of Cookies | Purpose | Who Serves (for example ) |
| Essential | These Cookies are required for the operation of the Services and enable you to move around the Services and use its features. Disabling these Cookies can negatively impact the performance of Services. | |
| Functionality | These Cookies are used to recognize you when you return to the Site. This enables us to personalize content for you and remember your preferences. These Cookies also enable your interactions with the Services such as emailing us. | |
| Analytics, Performance, and Research | These Cookies, beacons, and pixels allow us to analyze activities on the Services. They can be used to improve the functioning of the Services. For example, these Cookies recognize and count the number of visitors and see how they move around the Services. Analytics Cookies also help us measure the performance of our advertising campaigns to help us improve them and to optimize the content on the Services for those who engage with our advertising. | |
| Social Networking | These Cookies are used to enable you to share pages and content that you find interesting on our Services through third-party social networking and other websites. These Cookies may also be used for advertising purposes. | |
| Advertising | These Cookies and pixels are used to deliver relevant ads, track ad campaign performance, or track email marketing. |
We do not use any cookies, pixels, or other tracking that discloses to any third party information that identifies a person as having viewed specific video materials.
How Long Do Cookies Stay on My Device?
Some Cookies operate from the time you visit the Services until the end of that particular browsing session. These Cookies, which are called “Session Cookies,” expire and are automatically deleted when you close your Internet browser.
Some Cookies will stay on your device between browsing sessions and will not expire or automatically delete when you close your Internet browser. These Cookies are called “Persistent Cookies” and the length of time they will remain on your device will vary from Cookie to Cookie. Persistent Cookies are used for a number of purposes, such as storing your preferences so that they are available for your next visit and to keep a more accurate account of how often you visit the Services, how your use of the Services may change over time, and the effectiveness of advertising efforts.
Managing Your Cookies
It may be possible to block Cookies by changing your Internet browser settings to refuse all or some Cookies. If you choose to block all Cookies (including Essential Cookies), you may not be able to access all or parts of the Services.
You can find out more about Cookies and how to manage them by visiting www.AboutCookies.org.
Does the Site Respond to “Do Not Track” Signals?
At this time, our Site does not respond differently based on a user’s Do Not Track signal.
How We Use the Personal Information
We use personal information we collect about you or that you provide to us in the following ways:
- To present our Services and its contents in a suitable and effective manner for you and your device;
- To provide you with products, information, or Services that you request from us;
- To advertise opportunities, services, or special events that we think may be of interest to you;
- To provide customer support, troubleshoot issues, manage accounts, and respond to requests, questions, or comments;
- To carry out our obligations and enforce our rights arising from any contracts; and
- To notify you about any additions, upgrades, or changes in our Services.
How We Share Personal Information
With Your Consent:
The Services were created in order to give you control over your personal information. In the course of using our Services or Site, you may consent to the sharing of your personal information with various third parties.
Access and use by third-party service providers:
From time to time, Naenu enters into arrangements with companies whose expertise is essential for our own services to function properly. We disclose to these service providers only such personal information as is reasonably necessary to perform these functions, and any such third parties will be under an obligation to us to maintain the confidentiality of your personal information.
Access and use by subsidiaries or affiliated companies:
No Affiliates or subsidiaries exist for Naenu, Inc. at this time.
Access by other nonaffiliated third-party companies:
No other third parties exist at this time.
For legal purposes:
Naenu reserves the right to cooperate with local, provincial, state, federal and international officials in any investigation requiring either personal information or reports about lawful of unlawful user activity on this site. We also reserve the right to share your personal information to establish, exercise, or defend our legal and property rights, including providing information to others for the purposes of fraud prevention. We may also share your personal information with any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
If Naenu is ordered by a legal process or government to provide data about one or more individual users, we will notify those users of our compliance with that order, to the extent permitted by law.
Business transactions or mergers:
Naenu reserves the right to share your personal information to third parties as part of any potential business or asset sale, merger, acquisition, investment, round of funding, or similar type of transaction.
Bankruptcy or insolvency:
In the event of bankruptcy, insolvency, or dissolution proceedings, we may share your personal information with third parties as part of the sale or reorganization process.
Advertising and Marketing Choice
We respect your rights in how your personal information is used and shared. If at any time you would like to unsubscribe from receiving future emails, you can email us at: support@mementos.one as well as follow the instructions at the bottom of each email and we will promptly remove you from all correspondence. Please note, however, that we may still need to contact you regarding other matters.
European Users’ Rights
This section of our Privacy Policy is applicable to persons located in the European Union (“EU”), an European Economic Area member state (“EEA”), United Kingdom (“UK”), or Switzerland as well as to persons whose personal information is processed in or transferred from the EU, EEA, UK, or Switzerland. You are entitled under the EU General Data Protection Regulation and UK General Data Protection Regulation (collectively, the“GDPR”), to the information in this section of our Privacy Policy.
Your Rights
You are entitled by law to access, correct, amend, or delete personal information about you that we hold. A summary listing these rights appears below. Please note that these rights are not absolute and certain exemptions may apply to specific requests that you may submit to us.
To exercise these rights, please contact us using the information below in the “Contact Us” section. For your protection, we may need to verify your identity before responding to your request. In the event that we refuse a request, we will provide you a reason as to why.
Asking us to access your personal information
You have the right to obtain from us confirmation as to whether or not we are processing personal information about you, and if so, the right to be provided with the information contained in this notice. You also have the right to ask us for copies of your personal information. When making a request, please provide an accurate description of the personal information to which you want access. Where requests are repetitive or manifestly unfounded or excessive, we may charge a reasonable fee based on administrative cost.
Asking us to rectify your personal information
You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Asking us to delete your personal information
You have the right to ask us to erase your personal information if:
- We no longer need it for the purposes for which we collected it;
- We have been using it with no valid legal basis;
- We are obligated to erase it to comply with a legal obligation to which we are subject;
- We need your consent to use the information and you withdraw consent; or
- You object to us processing your personal information where our legal basis for doing so is our legitimate interests and there are no overriding legitimate grounds for the processing.
However, this right is not absolute. Even if you make a request for deletion, we may need to retain certain information for legal or administrative purposes, such as record keeping, maintenance of opt-out requirements, defending or making legal claims, or detecting fraudulent activities. We will retain information in accordance with the “How Long Is Your Personal Information Kept” section below.
If you do exercise a valid right to have your personal information deleted, please keep in mind that deletion by third parties to whom the information has been provided might not be immediate and that the deleted information may persist in backup copies for a reasonable period (but will not be available to others).
Asking us to restrict our use of your personal information
You have the right to ask us to place a restriction on our use of your personal information if one of the following applies to you:
- You contest the accuracy of the information that we hold about you, while we verify its accuracy;
- We have used your information unlawfully, but you request us to restrict its use instead of erasing it;
- We no longer need the information for the purpose for which we collected it, but you need it to deal with a legal claim; or
- You have objected to us using your information, while we check whether our legitimate grounds override your right to object.
The right to transfer your personal information to another service provider
You have the right to ask that we transfer the personal information you gave us from one organization to another, or give it to you (i.e. data portability). This applies to personal information we are processing to service a contract with you and to personal information we are processing based on your consent.
The right to withdraw consent
If we obtain your written consent to collect and process your personal information, you can subsequently withdraw such consent as to any further processing of such information.
The right to lodge a complaint with a supervisory authority
If you believe your rights under the GDPR have been violated, the GDPR gives you the right to file a complaint with your supervisory authority. A list of supervisory authorities is available here: EEA and EU Data Protection Authorities (DPAs); Swiss Federal Data Protection and Information Commissioner (FDPIC); UK Information Commissioner’s Office (ICO).
Rights related to automated decision-making
To the extent that we engage in decision-making based solely on automated processing, including profiling, which produces legal effects concerning you or which significantly affects you, you have the right not to be subject to such decision-making.
Right to object to processing
You have the right to object to the processing of your personal information that is based on legitimate interests or your consent (rather than when the reason for using it is to perform an obligation due to you under a contract with us). If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or we can demonstrate the processing is for the establishment, exercise, or defense of legal claims. You can object to the processing of your personal information by contacting us using the information in the “Contact Us” section below.
Legal Bases for Processing Your Personal Information
Naenu collects your personal information to provide our products and services to you; otherwise, we may not be able to process the transactions you request. We will only process your personal information when we have a lawful basis for doing so. If you are in a country in the EU, EEA, UK, or Switzerland, you are entitled to an explanation of the legal bases we rely on to process your personal information. The legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it, which is discussed below.
- Consent. We may process your personal information based on your consent such as when you purchase a service or ask us to send you certain kinds of marketing communications. You have the right to withdraw your consent at any time without affecting the lawfulness of the processing based on consent before its withdrawal.
- Our Legitimate Interests. We may process your personal information if doing so is necessary for our legitimate interests relating to our business purposes arising from your relationship with us, and your rights as an individual do not override those legitimate interests. For example, our legitimate interests include but are not limited to when we process your personal information to carry out fraud prevention activities and activities to increase network and information security, identify usage trends, determine the effectiveness of promotional campaigns, expand our business activities and improve our services and the content and functionality of our Services. Our legitimate interests also include providing you with the products and services you request, view, engage with, or purchase and communicating with you regarding your account or transactions with us.
- To Perform a Contract. We may process your personal information to administer and fulfill contractual obligations to you. We will also collect and process your personal information as necessary for the performance of a contract to which you are a party
- To Enable Us to Comply With a Legal Obligation. We may process your personal information to comply with legal obligations to which we are subject. This may include any requirement to produce audited accounts, any legal obligation to share information with law enforcement agencies, public or governmental authorities, and to comply with legal process.
- Necessary for the Exercise or Defense of Legal Claims. If you bring a claim against us or we bring a claim against you, we may process your personal information in relation to that claim.
Depending on the situation, we may be the controller or the processor for personal information collected from residents of the EU, EEA, UK or Switzerland. If you have any questions about or need further information concerning the legal basis on which we collect and use your personal information for any specific processing activity, please contact us using the “Contact Us” section below.
Cross-Border Transfers of Personal Information
Personal information about you provide while in the EU, an EEA member state, the UK, or Switzerland may be transferred to the United States. The United States does not have an adequacy decision or adequacy regulation. The GDPR permits such transfers when necessary for the performance of a contract between you and us, if we obtain your explicit consent to such transfer, or if it is in our legitimate interest to transfer the personal information. The laws in the United States may not be as protective as the GDPR or the laws of other jurisdictions where you may be located. If we transfer personal information from the EU, EEA, UK, or Switzerland, or another country with cross-border transfer obligations, we will provide an appropriate safeguard, such as using standard contractual clauses.
To obtain a copy of the safeguard(s), please contact us using the information provided in the “Contact Us” section below
How Long Is Your Personal Information Kept
We will retain your personal information until the personal information is no longer necessary to accomplish the purpose for which it was provided. We may retain your personal information for longer periods for specific purposes to the extent that we are obliged to do so in accordance with applicable laws and regulations, to protect you, other people, and us from fraud, abuse, an unauthorized access, as necessary to protect our legal rights, or for certain business requirements.
We will delete your personal information when it is no longer necessary for the purpose for which it was collected, or upon your request, subject to exceptions as discussed in this Statement or under applicable law, contract, or regulation.
If you use our mobile application, you can delete your account by submitting a request to [support@mementos.one] or by deleting your account through the application itself. If you delete your account from within the application, we will delete the accompanying personal data.
Our Commitment to Data Security
The security of your personal information is important to us. We take various reasonable organizational, administrative, and technical measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction. If required by law to do so, we will notify you and/or the relevant supervisory authority in the event of a data breach.
However, we cannot and do not guarantee complete security, as it does not exist on the Internet.
Third Party Links
Naenu’s Services may contain links to third-party websites. When we provide links, we do so only as a convenience and do not endorse any products or services and are not responsible for any content of any third-party website or any links contained within. It is important to note that this Statement only applies to Naenu’s Services. We are not responsible and assume no responsibility for any personal information collected, stored, or used by any third party as a result of you visiting third-party websites. We also advise that you read the privacy notice of any third-party websites you choose to visit carefully.
Children’s Privacy
Protecting the privacy of the very young is especially important. Our Services are not intended for children under 18 years of age, and we do not knowingly collect personal information from children under 18. In the event that we learn that we have collected personal information from a child under age 18 without verification or parental consent, we will immediately delete that information. If you believe that we might have any information from or about a child under 18, please contact us using the information provided in the “Contact Us” section below.
Policy Changes
This Statement may change from time to time. We will post any changes to this Statement on this page, and you should check these terms when you use the Services. Your continued use of the Site constitutes acceptance of the most current version of this Statement
Contact Us
If you have any questions about this Privacy Policy, please contact us by email at support@mementos.one.